Restructuring four S Corps Into QSubs?

Yes you should be reporting the capital contributions. Under the old Form 5472 rules, it's true that only items that impacted taxable income would be reportable transactions. So, a capital contribution by you to the corporation would not be reportable, unless the equity contribution was somehow below or above a fair value contribution in exchange for services that you might provide for the corporation - essentially an imputed reportable transactions. When the IRS changed the Form 5472 rules to require non-U.S. owned single member LLC's, they expanded the reportable transaction definition to include virtually everything. The term “transaction” is defined in Treas. Regs. Section 1.482-1(i)(7) to include any sale, assignment, lease, license, loan, advance, contribution or other transfer of any interest in or a right to use any property or money, as well as the performance of any services for the benefit of, or on behalf of, another taxpayer. So, for example, contributions and distributions would be considered reportable transactions with respect to such entities. These amounts can be reported on Lines 12 and 25 with an explanatory footnote that clarities the amounts are capital contributions and not amounts that impact taxable income.

There is no harm in having several businesses BUT it is wisdom to focus your full energy on the best business out of your lot. Let that focused business give you all the income you need on ongoing basis. Then you need to develop systems so that business doesn't need your full time attention. And then only focus on the next one and so on. Till then just see that other businesses are just maintained.

Hi, I'm not in Oregon so you'll need to speak to a local tax expert to verify the details but here is how it works: When you issue points you're creating a liability. You owe something to someone. It's like a gym which sells a one-year membership, they're only supposed to recognize 1/12 of the sale in the month it was sold. 11/12 of the money actually is a liability called 'deferred revenue.' As each month goes by, they reduce their liability by 1/12 and credit that money to income because now it is 'earned.' In your case you sell points to merchants (who give them to consumers) but most of the money collected is now owed to consumers to redeem their points. This is not income, you're just holding money owed to someone else. A small portion of the money, your gross margin on points sales, would be recognized as revenue and would have to cover your overheads and give you your profit, if any. So your balance sheet will keep growing in cash and an offsetting liability. Your income statement will only recognize the small margin which is your profit from selling the points to the merchants. I hope this helps make it more clear. With this type of business you may wish to investigate whether it makes sense from a liability point of view to hold the funds owed to consumers in a trust account rather than just 'floating' the points. I could see problems arising if you ever dipped into this cash pool to cover your own expenses while trying to argue to tax authorities that you're holding the cash for someone else. If you'd like to learn more about how merchants account for their own proprietary point systems, just book a call with me. I worked in the loyalty field for a few years. Cheers Dave

Same as any other entity (or person). Entity pays taxes in it's domicile jurisdiction. Best you talk with a tax preparer in your home country to ensure you have all the details. And... If you're a US citizen + your SAAS company is generating massive cash, likely best to organize your entity in a low tax jurisdiction, like Bermuda which is home to Google, Intel, Verizon, etc. And... best wait till Trump's new tax bill passes. If he has his way, corporate taxes may drop to a point low enough to keep your business in the US.

Yo are talking apples and oranges. Capital gains are related to your basis not the form of payment. If you are a cash basis taxpayer, you pay taxes when you receive cash beyond your basis. We can help you with structure.